Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Violation of principles of natural justice - impugned order does not take into consideration the reply submitted by the petitioner and is a cryptic order - The High court held that the proper officer failed to adequately consider the petitioner's reply on its merits and did not afford the petitioner an opportunity to clarify or provide further details. Consequently, the court set aside the impugned order and remitted the matter to the Proper Officer for re-adjudication, directing the officer to specify the required details/documents within one week.
Violation of principles of natural justice - impugned order does not take into consideration the reply submitted by the petitioner and is a cryptic order - The High court held that the proper officer failed to adequately consider the petitioner's reply on its merits and did not afford the petitioner an opportunity to clarify or provide further details. Consequently, the court set aside the impugned order and remitted the matter to the Proper Officer for re-adjudication, directing the officer to specify the required details/documents within one week.
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